ML23361A151

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DOE Presentation for the Hfir Package -96 Amendment Request
ML23361A151
Person / Time
Site: 07105797
Issue date: 12/13/2023
From: Kendrick B
Oak Ridge, US Dept of Energy (DOE)
To:
Office of Nuclear Material Safety and Safeguards
References
Download: ML23361A151 (1)
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NRC Pre-Application for the High Flux Isotope Reactor (HFIR) Fresh Fuel Shipping Containers Brandon Kendrick SARP Coordinator, High Flux Isotope Reactor NRC One White Flint North 11555 Rockville Pike, Rockville, MD ORNL is managed by UT-Battelle, LLC for the US Department of Energy

High Flux Isotope Reactor The Oak Ridge National Laboratory HFIR shipping containers deliver the inner and outer fuel elements required for reactor isotope production and neutron scattering research; the reactor has used more than 1000 fuel elements since becoming operational in 1965.

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Outline

  • Background - HFIR Packaging History
  • HFIR B(U)F-96 Certificate of Compliance Amendment Request
  • HFIR Packaging Contents
  • Packaging Design Overview (prototype fabrication)
  • Structural Evaluation
  • Thermal Evaluation
  • Containment Evaluation
  • Shielding/Criticality Evaluation
  • Application Submittal
  • Closing Discussion 3

Background - HFIR Packaging History

  • There are two HFIR shipping container designs, an Inner and Outer, with each designation specified according to the type of unirradiated fuel core contained within.
  • The containers were designed by ORNL Engineering in the mid-60s and approved for use by the ORNL Field Office under the U.S. Atomic Energy Commission (AEC) in 1965 as a Type B(U)F package.
  • In 1975, the AEC was superseded by the U.S. government Energy Research and Development Administration (ERDA) and the civilian Nuclear Regulatory Commission (NRC) were created. In 1977, ERDA became part of the Department of Energy (DOE).
  • In 1979, the HFIR packaging designs were certified under the newly centralized regulatory authority of the Department of Energy. (DOE certification was dropped in 1999.)
  • In 1979, the Nuclear Regulatory Commission issued a certificate for the HFIR packaging and subsequently certified it for use. That certification remains in effect today.

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HFIR B(U)F-96 Certificate of Compliance Amendment Request

  • The current certificate of compliance (CoC) for the Inner Shipping Container, and Outer Shipping Container, Model 5797, is valid through October 31, 2027, as a Type B(U)F package.
  • The CoC is issued to the U.S. DOE based on the ORNL HFIR Unirradiated Fuel Element Shipping Container, SARP, ORNL/TM-11656.
  • The HFIR packagings were fabricated in the 1960s and as such have been grandfathered for use through changes to the Code for Federal Regulations to present day under 10 CFR §71.19.
  • Regulatory changes to Title 10 of the Code of Federal Regulations Part 71 made in 2004 adopted the crush test for fissile material packages for consistency with the IAEA safe transport regulations.
  • To comply with the latest NRC regulations and planned packaging replacements, the HFIR containers were evaluated to demonstrate their design would meet current regulations, including the crush test for fissile packages.
  • This pre-application meeting summarizes the current HFIR SARP and results from recent regulatory testing performed to demonstrate -96 package compliance.

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HFIR Inner Packaging Content - Inner Fuel Element Each fuel plate is 50 mils thick with a 171 involute fuel 50-mil flow channel plates. between plates.

Enriched uranium in the form of U3O8-Al and B4C.

Fuel element Gross wt. 105 lbs. side plate Inner Fuel Element 6 Chapter 1

HFIR Outer Packaging Content - Outer Fuel Element 369 involute fuel Each fuel plate is plates. 50 mils thick with a 50-mil flow channel Enriched between plates.

uranium in the form of U3O8-Al.

Fuel element Gross wt. 205 lbs. side plate Outer Fuel Element 7

HFIR Simulated Fuel Content for Testing - I1 & O1 Lead Sheet Inner Fuel Element w/o lead 96 lbs; ~ 105 lbs with lead sheeting.

Outer Fuel Element w/o lead 186 lbs; ~ 205 lbs with lead sheeting.

The simulated fuel elements differ slightly from current HFIR production elements and were used as a proof of concept when they were fabricated in the 1960s.

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HFIR Mock Fuel Content for Testing - I2 & O2 Dum 19-04 Dum 19-03 Lead Sheet Outer Fuel Element w/o Inner Fuel Element w/o lead 190 lbs; ~ 205 lbs lead 98 lbs; ~ 105 lbs with lead sheeting.

with lead sheeting.

Mock fuel elements match the current HFIR production elements except for the fuel (uranium) loading. Lead sheeting was added to the inside diameter (ID) of each element to simulate the increased weight associated with uranium.

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Packaging Design Overview 16 - 3/8-inch bolts secure each lid to the drum flanges 35.5 29.5 45 48 Drum O.D. 25-inch Drum O.D. 31.5 inch C3x4.1 channel C3x4.1 channel Inner Element Package Outer Element Package Gross wt. 660 lbs. Gross wt. 1,050 lbs.

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Packaging Design Overview Polyethylene cushioning Lift rod Lower block plywood assembly 1/4 to 1 Lid Plywood plywood exploded assembly Drum 11

Packaging Design Overview 11-ga ASTM A1011 1/8-inch Neoprene gasket 2-inch pine post 1-inch polyethylene Inner Fuel Element Outer Fuel Element Fuel Cavity Fuel Cavity I.D. 10-7/8 by I.D. 17-3/8 Height 30-1/4 Height 31-1/8 Douglas Fir Plywood C3x4.1channels provide a means for C-channel moving the containers by fork-lift ASTM A36 12 Chapter 1

HFIR Packaging Structural Evaluation - Testing Two Inner and two Outer HFIR Packages were subject to 10 CFR §§ 71.71 and 71.73 structural testing by the Savannah River National Laboratory Packaging Technology Organization, Aiken, South Carolina.

Inner Packaging Outer Packaging 13 Chapter 2

HFIR Structural Evaluation - Normal Conditions of Transport Test Packages Inner - 1 Outer - 1 Inner -2 Outer -2 Initial Conditions *10 CFR § 71.71 -40ºF/Ambient Ambient Ambient Ambient Cold -40ºF (c)(2) VTU Vibration (c)(5) - - VTU VTU Water Spray (c)(6) VTU VTU VTU VTU Free Drop 4-ft (c)(7) CGT CGT TD H Compression (5x) (c)(9) VTU VTU Penetration (c)(10) - - H H

  • Reduced/Increased external pressure (c)(3&4) (analysis); Corner Drop 1-ft (c)(8) not required Environmental Chamber -40ºF cold test, 64 hrs 2 in/hr for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Low & High Compression 24 hrs Frequency Vibration 14

HFIR Structural Evaluation - NCT Acceptance Criteria Package performance under NCT must demonstrate that there is no loss or dispersal of radioactive contents as demonstrated to a sensitivity of 106A2 per hour, no significant increase in external surface radiation levels, and no substantial reduction in the effectiveness of the packaging for shielding, heat transfer, and maintaining subcriticality.

Minimum applied acceptance criteria following NCT testing*:

-40ºF test:

1. There must be no visible damage to the container or contents.

NCT Drop test:

1. Container lid shall remain in place.
2. Body of container shall remain intact with no penetration large enough for a fuel plate to pass through.
3. The geometric form of the fuel element shall remain essentially unaltered.
4. The maximum diameter of the body of the container shall not be reduced by more than 5%, and
5. The total effective volume of the container, as measured by the external dimension, shall not be reduced by more than 5%.
  • ORNL/RRD/INT-175, Test Plan for NCT and HAC Tests ORNL Package Design USA/5797/B(U)F-96: Acceptance Criteria 15

HFIR Structural Evaluation - NCT Results Test Packages Inner - 1 Outer - 1 Inner -2 Outer -2 Initial Conditions 10 CFR § 71.71 -40ºF/Ambient Ambient Ambient Ambient Cold -40ºF (c)(2) VTU Vibration (c)(5) - - VTU VTU Water Spray (c)(6) VTU VTU VTU VTU Compression (5x) (c)(9) VTU VTU I1: Cold test -40ºF: Some condensed water was collected post inspection of the container. No other anomalies observed.

I2 & O2: Vibration: No anomalies were observed post inspection of the containers and fuel elements.

I1, I2, O1 & O2: Water Spray: Water ingress was observed around the gasketed lid of I1 and O1.

As a result, I2 and O2 were subjected to the water spray test prior to NCT drops. Water ingress had no observable effect on package performance.

I1 & O1: Compression: The compression test had no measured effect on package performance.

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HFIR Package 4-Foot Free Drop Testing 660 lbs 1,150 lbs 4-ft Center of Gravity Top Down (TD) CGOT Horizontal (H) over Top (CGT) Inner #2 Outer #1 Outer #2 Inner #1 The penetration test following NCT 4-ft drops was only performed on test packages I2 &

17 O2 due to minimally observed damage.

Chapter 2: Structural Evaluation - NCT Free Drop Results I1 Inner-1: 4-ft free drop CGT Top left pictures the overall package damage to the package from the initial and secondary drop impact. Top right shows some bending of the forklift channel structure.

Bottom left shows deformation of the lid/flange lip due to the initial impact on the lids 2x2x1/4 structural channel.

Opposite the lip deformation a small ~3/8 gap between the lid and drum flange opened. No other damage was observed.

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Chapter 2: Structural Evaluation - NCT Free Drop Results I2 Inner-2: Top Down 4-ft free drop.

Four quadrants pictured. Drum remained upright. Lid structural angle iron deflected slightly inward resulting in some slight gaps between lid and body flange as measured pre- and post-drop. No other damage observed.

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Chapter 2: Structural Evaluation - NCT Free Drop Results O1 Tamper Indicating Device (TID) position between 2x2x3/16 angle Outer 1: Center of Gravity over Top 4-ft free drop The drop impacted the TID position of the package. The top picture shows the overall damage to the package from the initial and secondary impact (unlike I1 no other secondary damage was observed). The bottom left picture also shows deformation to the lid reinforcing 2x2x1/4 angle adjacent to the initial impact. The bottom right presents a profile view of the TID position deformation.

No other damage was observed other than scuffing of the package in its secondary impact.

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Chapter 2: Structural Evaluation - NCT Free Drop Results O2 Lid TID position Outer 2: Horizontal 4-ft free drop The drop impacted the TID position of the package lid. The top left picture shows the package lid deformation from the initial impact. The top right the bottom of the drum, where no damage was observed. The drum was rotated and the bottom left picture shows profile deformation to the lid/flange between adjacent bolts. The bottom right identifies some minor damage to the rolled 1x1x1/8 drum stiffening angles. No other damage was observed other than scuffing of the package in its secondary impact.

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Chapter 2: Structural Evaluation - NCT Penetration Results I2 & O2 I2 O2 I2 test setup Due to the negligible amount of damage from the penetration test only I2 and O2 packages were tested. I2 test setup is pictured left. Damage from I2 and O2 are shown in the pictures to the right. The test report fully summarizes all tests that were performed.

Penetration bar (13 lbs, 1.25-inch diameter). The bar was positioned perpendicular to the packages striking the 11 ga (~0.12-inch) thick drum shell resulting in an approximately nickel sized dent less than 1/16-inch deep on each package. No other damage observed.

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Chapter 2: Structural Evaluation - NCT Test Summary Test Packages Inner - 1 Outer - 1 Inner -2 Outer -2 Initial Conditions 10 CFR § 71.71 -40ºF/Ambient Ambient Ambient Ambient Cold -40ºF (c)(2) VTU Vibration (c)(5) - - VTU VTU Water Spray (c)(6) VTU VTU VTU VTU Free Drop 4-ft (c)(7) CGT CGT TD H Compression (5x) (c)(9) VTU VTU Penetration (c)(10) - - H H Four packages were tested, 2 -inner and 2 -outer containers, containing simulated HFIR fuel elements.

  • Cold test - No damage was observed to the packaging or the simulated fuel content. A small amount of water was collected in the polyethylene bag due to condensation.
  • Vibration - No damage was observed to the packaging or the simulated fuel content.
  • Water Spray - No damage was observed to the packaging or the simulated fuel content. However, water ingress was seen (staining) and or measured on all 4 packages. No free water was observed on inspection. Some water was observed coming from the containers when oriented for the CGOT free drop.
  • Free Drop - No damage was observed that exceeded the regulatory NCT and or ORNL acceptance criteria.
  • Compression - No damage was observed or measured.
  • Penetration - No damage that exceeded the regulatory NCT and or ORNL acceptance criteria.

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HFIR Structural Evaluation - Hypothetical Accident Condition Testing Test Packages Inner - 1 Outer - 1 Inner -2 Outer -2 Initial Conditions 10 CFR § 71.73 -20ºF -20ºF 100ºF 100ºF Free Drop (30-ft) (c)(1) CGT CGB CGT TSD Crush (1,100 lb. (c)(2) H CGB H H plate from 30 ft)

Puncture (40-in) (c)(3) H CGB CGB H Thermal *(c)(4) - - - -

Immersion 3-ft, 50-Ft *(c)(5&6) - - - -

Special **10 CFR § 71.61 - - - -

requirements Type B

  • Thermal and Immersion evaluation by analysis;
    • Special requirements for Type B not required, content is less than 105A2 HAC tests were preceded by NCT tested packages.

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HFIR Structural Evaluation - Potential Failure Criteria*

Significant reduction in container confinement boundary effectiveness, sufficient to result in partial or full fuel exposure during thermal event.

Significant reduction in container bottom effectiveness, sufficient to result in a breach that could affect fuel exposure during thermal event chimney effect - initiated wood impact limiter smoldering.

Fuel deformation sufficient to compromise fuel integrity.

Impact limiter laminate structure failure (fuel damage from plywood delamination buckling, joint failure, splintering, slippage).

  • ORNL/RRD/INT-174, Test Plan for NCT and HAC Tests ORNL Package Design USA/5797/B(U)F-96: Bases for Selecting Tests, Orientations, and Test Conditions.

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HFIR Structural Evaluation - HAC Acceptance Criteria Package performance under HAC must demonstrate that the packaging satisfies the containment, shielding, and subcriticality requirements of 10 CFR §§ 71.51(a)(2) and 71.55(e).

  • No release of radioactive material exceeding an A2 value in one week (Krypton not applicable)
  • Dose rate <1 rem/hr at 40 inches from the container
  • Remain subcritical Minimum applied acceptance criteria following testing*:
1. Container lid shall remain in place.
2. Fuel plates in the mock elements shall not deform more than 90 degrees in any portion of the fuel bearing portion of the plate.
3. Package damage shall not permit the maximum surface temperature of the fuel element to exceed 1000ºF, and
4. The fuel plates shall not be ejected from the fuel element side plates.
  • ORNL/RRD/INT-175, Test Plan for NCT and HAC Tests ORNL Package Design USA/5797/B(U)F-96: Acceptance Criteria 26

HFIR HAC Sequential Free Drop, Crush, Puncture - I1 1,100 lb 40x40 Crush Plate CGT Puncture Drop 30-ft 40-in H

Inner #1 (-20ºF) 27

HAC Test Results - I1 CGT 30-ft Drop (-20ºF)

Lid reinforcing angle Second set of bolts 68º Pre-existing damage from 4ft CGT drop 30-ft drop damage Secondary damage resulting from L package rotation on impact Inner 1: CGT 30-ft drop 30 ft drop damage: Left picture shows the overall package damage from the initial and secondary drop impact. The drop targeted the pre-existing damage from the 4-ft at the lid reinforcing angle. The impact symmetrically deformed the lid/flange down into the top drum reinforcing angle through to the second set of bolts adjacent to the lid reinforcing angle (~ 68 degrees). Secondary impact flattened the lower drum stiffening angle and partially flattened the center angle. The lid remained securely in place. No other damage was observed.

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HAC Test Results - I1 Horizontal Crush (-20ºF)

Crush plate impact line Side facing pad R

Pre-existing damage from 30ft CGT drop L

Crush damage: Left picture shows the damage to the package side facing the pad.

The right picture shows damage imparted by the crush plate 180 degrees from the Inner 1: Horizontal Crush pad. The crush plate squarely impacted the center of the drum flattening and Crush - damaged side pushing the stiffening angles flush to the drum wall and shearing the bolt head from 30-ft facing pad immediately adjacent to the TID position. The lid remained securely in place. No other damage was observed.

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HAC Test Results - I1 Puncture (-20ºF) 6-inch diameter puncture mark near position #9 Similar puncture damage was observed where the puncture test was performed.

Pre-existing damage from Horizontal crush Puncture damage: The package squarely impacted the puncture post (at marked Inner 1: Horizontal Puncture position 9 inline with crush damage) almost remaining stuck if not for the lifting straps as observed in high speed video. The lid remained securely in place. The puncture Center of package test does not result in any significant damage to the package.

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HAC Nondestructive Test Results X-RAY - I1 No visible fuel element damage Impact damage from drop and crush.

Composite x-ray images of I1 following NCT and HAC testing. Damage to the lid area of the package can be seen in the 0 and 90 shots. Also in these images there is no apparent damage to the inner fuel element.

The lead sheet glued into the inner element ID to increase its weight remains in position.

31 Chapter 2

HFIR HAC Sequential Free Drop, Crush, Puncture - I2 Crush Plate Puncture CGT Drop 30-ft 40-in Inner #2 (100ºF) 32

HAC Test Results - I2 (100ºF)

CGT - on TID position Crush - damaged side Puncture - CGB on crush damage from 30-ft facing pad 33

HFIR HAC Sequential Testing:

Free Drop, Crush, Puncture - O1 Puncture Crush Plate Free Drop CGB 30-ft CGB 40-in Outer #1 (-20ºF) 34

HAC Test Results - O1 (-20ºF)

CGB 30-ft drop CGB crush CGB Puncture 35 Chapter 2

HFIR HAC Sequential Testing:

Free Drop, Crush, Puncture - O2 Safety post Crush Plate Puncture TSD 15º 30-ft 40-in Outer #2 (100ºF) 36

HAC Test Results - O2 (100ºF)

Top Slap Down 30-ft drop Horizontal Crush Horizontal Puncture 37 Chapter 2

HAC Nondestructive Test Results X-RAY - O2 38 Chapter 2

Thermal Evaluation - Analysis Component Material Function for NCT and HAC Outer packaging 11 ga carbon steel (painted yellow); Provides confinement for the fuel element (lid & drum body) angle iron stiffeners not included in and form for thermal and impact protection thermal model. materials Energy Absorber Douglas Fir plywood (cut and glued Provides thermal insulation and impact (plywood assembly) sheets) protection for the fuel element Shock absorber Polyethylene foam Provides shock absorption and cushioning to the fuel assembly during transport Payload Fuel plates U3O8 Cermet fuel contained (sandwiched) within each fuel assembly plate Fuel Assembly Aluminum Provides containment of the cermet U3O8 fuel within the fuel (plates) assembly.

Inner element package analyzed without fuel 39 Chapter 3

Containment Evaluation - Analysis

  • The HFIR fuel is a blend of metal-oxide U308 ceramic (cer) and aluminum metal (met) materials produced by powder metallurgy under high heat and pressure.
  • The cermet fuel matrix is clad between aluminum sheets making a singular fuel element plate.
  • Radioactive material containment is provided by the aluminum bonded to the U3O8-Al fuel matrix of each plate.
  • 10 CFR § 71.51(a)(1) requires under NCT any release of radioactive material be less than 10-6 A2 per hour.
  • 10 CFR § 71.51(a)(2) requires under HAC any release of radioactive material be less than 1 A2 per week.
  • Containment of the radioactive material is demonstrated by the performance of the packaging and the fuel elements under NCT and HAC.

40 Chapter 4

Containment Criteria Acceptance Criteria

  • No fuel plate is bent greater than 90 degrees under NCT and HAC.
  • The temperature of the fuel plates remain less than 1,000°F under HAC.

Containment Criterion - NCT

1. No measurable/detectable smear surveys of the external surfaces of the fuel elements for contamination on any fuel assembly greater than 1,000 dpm.

Containment Criterion - HAC

1. No release of greater than 90% of fuel cermet from an inner assembly.
2. No release of greater than 34% of fuel cermet from an outer assembly.

41 Chapter 4

Shielding Evaluation - Summary of Package Dose Rates HEU Fuel Package Surface (mrem/hr) 2 meters from surface (mrem/hr)

Side Top Bottom Side Top Bottom Normal Conditions Gamma 9.0 4.2 4.0 0.4 0.5 0.5 Neutron - - - - - -

Total (Limit 200) 9.0 4.2 4.0 0.4 0.5 0.5 Side Top Bottom Side Top Bottom Hypothetical Accident Conditions Gamma 9.0 4.2 4.0 0.4 0.5 0.5 Neutron - - - - - -

Total (Limit 1000) 9.0 4.2 4.0 0.4 0.5 0.5 Typical transport index (TI)of 0.1 is assigned at transport based on 1-meter dose measurements.

42 Chapter 5

Criticality Evaluation - Analysis Criticality Criteria used to Demonstrate Compliance:

1. The criticality safety evaluation includes the single Package analyses required by 10 CFR § 71.55 and array analyses for Normal Conditions of Transport (NCT) and Hypothetical Accident Conditions (HAC) required by 10 CFR § 71.59
2. Determination of the Criticality Safety Index (CSI) for the Inner and Outer HFIR shipping package required by explicit equations specified in 10 CFR § 71.59 Both package analyses included computations of fully submerged and water flooded single undamaged and damaged packages, nearly optimally water moderated and water reflected arrays of more than 250 damaged or undamaged packages, and nearly optimally water moderated infinite arrays of undamaged or damaged packages 43 Chapter 6

Criticality Evaluation - Summary of Package HAC Array Condition Results Inner Element Outer Element NCT Array Max Keff, Infinite Array as shipped 0.37351 0.50705 Max Keff, Infinite Array with 0.67197 0.74138 Optimum interspersed material HAC Array Max Keff 0.78532 0.87308 Number of Packages (N) 252(63x4) 260(52x5)

CSI 0.4 (50/(N=252/2) 0.4 (50/(N=260/2) 44 Chapter 6

Package Operations Mock unloading Mock unloading Mock unloading Mock loading With polyethylene bag 45

Package Operations

  • Other Operations

- Special equipment for transport

- Tie-down bands for tie-down

- Specialize metal pallets that restrict longitudinal and lateral movement during shipment

- Packages transported by Secure Transportation Tie-down bands Specially designed metal pallets used for storage and handling.

46 Chapter 7

ACCEPTANCE TESTS AND MAINTENANCE PROGRAM

  • Visual Inspections and Measurement

- Performed throughout fabrication process, dimensional, visual, and component weights.

  • Weld Examinations

- Inspection methods, weld procedures, personnel qualifications, and weld reports shall meet AWS D1.1, as appropriate.

  • Structural and Pressure Tests

- The containers have no pressure boundary; therefore, no pressure tests are required.

  • Leakage Tests

- There are no designed leak testable boundaries; therefore, no leak tests are performed.

  • Component and Material Tests

- As required by receipt inspection of the containers upon delivery

  • Shielding Tests

- Not applicable; containers are not designed with specific materials to attenuate dose 47 Chapter 8

MAINTENANCE PROGRAM

  • Structural and Pressure Tests

- The containers have no pressure boundary; therefore, no periodic pressure tests required.

  • Leakage Tests

- There are no designed leak testable boundaries; therefore, there are no periodic leak tests performed.

  • Component and Material Tests

- As required by receipt inspection of the containers upon delivery

  • Thermal Tests

- Not applicable; containers are not designed with specific materials to facilitate heat transfer 48 Chapter 8

Quality Assurance The ORNL Packaging and Transportation Quality Program has been approved by DOE (2019).

Packaging Owner

- DOE Design Authority

- UT-Battelle (ORNL)

Package user

- ORNL, BWXT, Y-12 10 CFR 71 Subpart H ASME NQA-1 DOE Order 460.1 49 Chapter 9

Quality Assurance Component Material Function for NCT and HAC QA Category Outer packaging 11 ga carbon steel (painted yellow); angle Provides confinement for the fuel iron stiffeners not included in thermal element and form for impact and C model. thermal protection materials.

Energy Absorber Douglas Fir plywood (cut and glued Provides thermal insulation and impact (plywood assembly) sheets). protection for the fuel element. C Shock absorber Polyethylene foam. Provides shock absorption and cushioning to the fuel assembly during C normal conditions of transport.

Fuel Covering Polyethylene bag or wrap. Provides a clean barrier between the fuel element and shock absorber during NCT. Non-Safety Safety post Pine. Provides a physical obstruction preventing nesting of an inner fuel element withing an outer fuel element Non-Safety packaging (only on the outer packaging).

Fuel Assembly Aluminum. Provides containment of the cermet U3O8 fuel within the fuel (plates) A assembly.

Lid Fasteners Alloy steel, ASTM A325, A193, or A449. Secures the lid to the body of the container and ensures the contents C remain in place during NCT and HAC.

50 Chapter 9

Application Submittal Container contents inspections December 2023 - February 2024 SRNL finalize Test Report March 2024 SARP Preparation December 2023 - March 2024 Internal and ORNL Site Office reviews April 2024 Submittal May 2024 51

Closing Discussion 52

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